What follows is the text of "Where the Wastes Are: Highlights from
the Records of the More than 5,000 facilities that receive transfers of
TRI chemicals." It was published in April 1994.
If you would like a hard copy of the report, contact OMB Watch at:
1742 Connecticut Ave, NW
Washington, D.C. 20009
(202) 234-8494
This electronic copy doesn't have any of the charts or tables, sorry.
WHERE THE WASTES ARE: HIGHLIGHTS FROM THE RECORDS OF THE MORE THAN
5,000 FACILITIES THAT RECEIVE TRANSFERS OF TRI CHEMICALS.
by Alair MacLean and Rich Puchalsky
EXECUTIVE SUMMARY
In June of 1992, a Rhone-Poulenc factory in Martinez, California,
exploded. Sulfuric acid had spilled and caught fire when it came in
contact with hot machinery. Two workers were critically injured.
One later died.
A year later, Gibraltar Chemical Resources in Winona, Texas, where
waste chemicals are injected deep underground, was ordered to clean
up contaminated groundwater on its site. By the fall, Gibraltar's
environmental problems had grown so large that the state ordered
the company to stop doing business temporarily.
What do these two facilities have in common? Each is among the top
facilities receiving transfers of toxic chemicals according to
information contained in the Toxics Release Inventory (TRI).
Earth Day Events
Soon, as it has for the last five years, the Environmental
Protection Agency will release its annual report on the fate of
toxic chemicals used in manufacturing, the TRI. The approximately
300 chemicals listed on the TRI are considered among the most
dangerous to human health and the environment. For example, many
can cause cancer. This year, as in the past, the media, the public
and regulators will focus on the pounds of toxic chemicals emitted
from manufacturing facilities around the country. Press releases
will compare this year's reported emissions to last. Discussion
will center on whether these facilities have reduced chemical
emissions or not.
But the Toxics Release Inventory tells another, little-noticed
story as well. Contained within manufacturers' yearly reports are
records of more than 80,000 transfers of chemicals to what are
called off-site facilities: recyclers, landfills, and incinerators.
In all, the approximately 23,000 manufacturers sent their toxic
chemicals to more than 5,000 off-site facilities. And, if history
is any guide, these facilities may pose health and environmental
dangers in the future. As of 1991, at least 112 sites on the
federal Superfund list had previously been engaged in recycling
hazardous waste.
Manufacturers reported releasing 3.4 billion pounds of toxic
chemicals to the air, land, and water in 1991, the most recent year
for which data are available. But they sent just as many pounds of
chemicals to be disposed at other facilities. In 1991,
manufacturers reported more than 3.4 billion pounds of transfers to
off-site destinations.
Some past analyses have looked at the aggregate number of pounds of
toxic chemicals sent from or received by different states. Yet, so
far, no one has compiled a national record of the actual sites that
receive these toxic chemical shipments. The difficulty of collating
and correcting the information has presented a formidable obstacle.
And there is a general perception that transferring chemicals
"solves" the pollution problems associated with releases.
But these transfers may just move short-term accidents and
long-term contamination from one site to another. And the towns
that host off-site destinations end up serving as a dumping ground
for the problems of industrial production.
This report presents the first examination of the top facilities
around the country that receive shipments of TRI chemicals in
waste. Using the 1991 TRI data, we have prepared a list
of the off-site destinations that receive the greatest poundage of
transfers of TRI chemicals from manufacturers. The facilities
receiving TRI chemicals are named and ranked (see Table 1: Top
Forty Facilities Receiving TRI Chemical Transfers). The top 40
facilities account for 1.7 billion pounds, 48 percent of all
chemicals transferred. For
example, the first, third and eighth largest recipients of TRI
chemicals are Rhone-Poulenc facilities in Hammond, Indiana, Carson,
California, and Baton Rouge, Louisiana. The second and seventh
largest recipients of TRI chemicals are General Chemical
facilities. A Timken facility in Canton, Ohio, is the fourth
largest recipient of TRI chemicals, and a Coulton Chemical facility
in Oregon, Ohio, is the fifth largest recipient. A Horsehead
Resource Development facility in Palmerton, Pennsylvania, is the
sixth largest recipient. Gibraltar Chemical in Winona, Texas, and
Petro-Chem Processing in Detroit, Michigan, occupy the number nine
and number ten spots. These top ten facilities receive more than
one quarter of all the TRI chemicals sent off-site.
The report also identifies the largest recipients of TRI chemicals
within specific categories, such as landfills and incinerators. The
landfill receiving the most TRI chemicals was operated by Pennfill
in Taylor, Michigan. The largest incinerator was operated by
Rollins in Baton Rouge, Louisiana. The company receiving the most
TRI chemicals for energy recovery was Arco Chemical in Channelview,
Texas. The facility receiving the most pounds of TRI chemicals to
be injected underground was Gibraltar in Winona, Texas. Rhone
Poulenc's facility in Hammond, Indiana, was number one on the list
of facilities receiving TRI chemicals for acid regeneration.
The report looks in detail at six companies that dominate selected
disposal or recycling methods: incineration, landfilling,
underground injection, energy recovery and acid regeneration. These
destinations for off-site transfers of TRI chemicals share a
history of short-term accidents and long-term contamination.
Recipients of TRI transfers have allegedly contaminated water
supplies:
In New Castle, Kentucky, a 1992 enforcement action by the
EPA of a Safety-Kleen energy recovery facility, the fourth largest
facility in terms of TRI shipments, alleged that the company had
contaminated the Bartlett Fork Creek with hazardous waste.
In Carlyss, Louisiana, based on inspections that began in
1988, the state has charged that the Chemical Waste Management
landfill, number six in terms of TRI shipments, allowed hazardous
wastes to contaminate the nearby ground and water.
In Winona, Texas, in 1993, the state ordered the
Gibraltar Company, operator of the largest underground injection
facility, to clean up contaminated groundwater.
Recipients of TRI transfers have had potentially dangerous
accidents:
In Carlyss, Louisiana, in 1988 and 1989, the Chemical
Waste Management landfill experienced a series of eight fires that
the company failed to report.
In Martinez, California, in 1992, the Rhone-Poulenc acid
regeneration facility, number 9 in terms of the weight of TRI
chemicals received, suffered a serious accident involving sulfuric
acid. Two workers were critically injured. One later died.
In Winona, Texas, in 1993, the Gibraltar facility had a
chemical reaction in a 15,000 gallon tank that released a toxic
plume.
And, in the same year, Gibraltar executives failed to
report another chemical accident until the day after it occurred.
Recipients of TRI transfers have allegedly received illegal waste
shipments:
In Deer Park, Texas, a Rollins Environmental Services
facility, the number two incinerator in terms of TRI shipments,
evidently received radioactive waste shipments during the eighties.
In Emelle, Alabama, in 1987, the Chemical Waste
Management landfill, number ten in terms of TRI transfers,
apparently illegally stored and transferred Agent Orange.
Facilities receiving TRI chemicals have been ordered closed by
local and federal regulators:
In Baton Rouge, in 1985, the state of Louisiana ordered
Rollins's incinerator, number one in receipts of TRI chemicals,
closed due to pollution problems. The incinerator is one of the few
businesses ever denied a tax incentive by the state because of
pollution problems.
In Manati, Puerto Rico, in 1992, the Safety Kleen
facility, the sixth largest incinerator in terms of TRI chemicals,
had stored more than 800,000 pounds of excess toxic waste on-site.
In addition, the facility was storing more than a million more
pounds of hazardous waste in un-permitted tanks on the north and
south coasts of Puerto Rico. The facility had to close temporarily
and the Puerto Rican Environmental Quality Board recently fine
Safety-Kleen more than $1.4 million dollars.
In Winona, Texas, in 1993, the Environmental Protection
Agency officially revoked the Gibraltar Company's right to inject
hazardous waste into one of its two underground injection wells
because of an 800 foot gap surrounding the well.
And, in the same year, the state ordered Gibraltar to
temporarily stop receiving hazardous wastes.
At least one of the companies has had prior involvement with a
Superfund site:
In Bridgeport, NJ, the Rollins incinerator, number three
in terms of its receipt of TRI chemicals, has been prosecuted by
the federal government as a Potentially Responsible Party in a
couple of Superfund cases. In a 1988 lawsuit, the company was found
to be a Potentially Responsible Party in the contamination of at
least one Superfund site: the Kin-Buc Landfill in Edison, NJ.
Recommendations
Many of the actions described above represent a failure of
compliance on the part of facilities that receive TRI chemicals. To
prevent the top recipients of TRI transfers from becoming the
Superfund sites of the future, greater attention should be focused
on these sites.
Shippers of TRI chemicals should try to reduce their use of toxic
chemicals in the first place. Toxics use reduction would limit the
number of pounds sent to off-site facilities. Additionally,
reduction of the use of toxic chemicals would lead to a decrease in
emissions of toxic chemicals as well.
Recipients of TRI chemicals should have to report their own
releases and transfers of the chemicals, in order to increase
accountability. Current law only covers certain large manufacturing
facilities. In 1991, these manufacturers reported that they sent
more pounds of chemicals off-site than they emitted directly to the
environment. Yet, the recipients of these off-site transfers do not
now have to report their own emissions to the environment.
Requiring landfills, incinerators and other hazardous waste
recycling and disposal sites to report their emissions of TRI
chemicals would greatly increase the accountability created by the
Right-to-Know.
Recipients of TRI chemicals should publicize their plans to prevent
chemical accidents, as well as back-up plans for responding to
chemical accidents should they occur. Local Emergency Planning
Committees, established by the law that created the TRI, could
theoretically take an active role in requiring manufacturers to
prepare accident prevention plans and in making those plans
available to the public. More recently, the Clean Air Act
Amendments established the first framework for making corporate
plans for chemical accidents publicly available. Under the current
draft of the regulations, manufacturers must allow the public to
see their assessments of the worst-case accidents. Hazardous waste
landfills and incinerators pose dangers as well. They should also
be required to enlist the public in planning for accidents.
Shippers of TRI chemicals should monitor the regulatory and
environmental histories of the companies to whom they ship waste.
The Superfund ensures that companies who ship waste that ends up in
an uncontrolled waste site must bear some share of the burden of
clean-up. With this expanded definition of liability, it is in TRI
shippers interest to monitor the fate of chemicals shipped
off-site.
EPA should ensure that the facilities receiving TRI wastes can
legally handle those wastes. While the largest recipients of TRI
transfers are likely to have permits to receive such waste. A
number of facilities that may not actually have permits to receive
TRI chemicals.
EPA should include examinations of off-site recipients in future
analyses of the Toxics Release Inventory. Through its annual report
on TRI chemicals, EPA each year spotlights manufacturers' releases
of toxic chemicals. But the agency has not consistently examined
the recipients of transfers. In the future, EPA should include
lists of the names of off-site destinations in its analyses of TRI
data.
Methodology
Toxics Release Inventory forms are filled out by the shippers of
the waste, not by the receivers. In order to determine the total
number of pounds received by different facilities, the 80,590
individual reported transfers needed to be added. But common errors
can make one destination look like two or more. The name or address
of a destination may be misspelled. This makes totaling the number
of pounds shipped to a particular destination difficult. For
example, Gibralter Chemical in Wynona, Texas, according to a
cursory examination of the database, would not be grouped with
Gibraltar Chemical of Winona, Texas.
We took a number of steps to correct common errors. First, a
computer program was used to standardize spelling for the names and
addresses of the transfers. After the computer had decreased the
number of apparent recipients of TRI transfers from 80,590 to
approximately 20,000 facilities, our staff examined the groups of
transfers that resulted to find matches that the computer could not
detect. Staff members searched through telephone directories to
find the phone numbers and then called the facilities to check the
addresses. Staff members also compared destinations listed in the
TRI with EPA's FINDS database (Facility Index System, a list of all
EPA-regulated facilities in most of EPA's major programs) to see if
they existed. And staff compared counties and states used in TRI
off-site transfer addresses with a reference dataset listing the
county and state of each zip code in the U.S. Finally, staff looked
at each individual transfer going to the largest poundage
destinations to make sure that none had been mis-assigned.
By using these methods, the 80,590 initial transfers were grouped
into about 5,300 destinations. We are confident that the possible
error introduced through grouping transfers will not greatly affect
the totals given for the destinations listed in this report.
A Few Words About the Totals in This Report
Totals given in this report are generally rounded off to the
nearest million pounds. In general, reporting all digits in a TRI
total should not be done since EPA only requires no more than 2
significant digits for reporting releases (Toxic Chemical Releases
Inventory Reporting Form R and Instructions, pg. 27). For this
report, transfers that were reported as "release ranges"
were counted as a number of pounds equal to the center of the range
(i.e. 1-10 pounds = 5 lbs, 11-499 lbs = 250 lbs, 500-1000 lbs = 750
lbs). Transfers to publicly-owned treatment works, or POTWs, are
not examined in this report and are not counted into any of our
totals.
INTRODUCTION
After the fatal accident in Bhopal, India, where a cloud of toxic
gas from a Union Carbide factory killed more than 2,000 people, the
U.S. Congress was spurred into action. Legislators drafted a law,
the Emergency Planning and Community Right-to-Know Act, that would
provide communities with the information and tools they needed to
plan for emergencies involving chemical accidents. One component of
this planning was an inventory of all of the toxic chemicals that
manufacturing facilities produce or use.
More than just giving individuals information about the chemicals
on-site, however, the Toxics Release Inventory allows anyone who
looks at it to get a clearer picture of where the toxic chemicals
in wastes are going. Companies have to report, for example, that
they released 200 pounds of chlorine to the air and another 300
pounds to the water (see Appendix A, "What Information Does the
TRI Contain?"). In addition, companies have to report if they
are sending these toxic chemicals to other destinations, such as
landfills or incinerators, to be disposed, treated or recycled.
Using these manufacturers' reports, we have generated lists of
incinerators, landfills and other off-site destinations that
received transfers of TRI chemicals.
With the exception of off-site transfers, companies' reports to the
TRI are fairly straight-forward. In 1991, for example, Chevron's
asphalt refinery reported emitting 1,400 pounds of Benzene to the
air in Portland, Oregon. By contrast, the actual fate of the 500
pounds of the chemical that Chevron sent to be incinerated by the
Chemical Handling Company in Broomfield, Colorado, is less certain.
This uncertainty is a function of the reporting structure of the
TRI. While manufacturing facilities such as Chevron are required to
report what they do with toxic chemicals, waste-handling facilities
such as the Chemical Handling Company are not.
When TRI chemicals arrive at off-site destinations they can be
treated or disposed of in various ways. Before 1991, TRI chemicals
sent to be recycled did not have to be reported. With the passage
of the Pollution Prevention Act, however, manufacturers began to
report these chemicals sent for recycling.
Many of the companies that we looked at have had recent regulatory
and environmental problems. For example, several of the dominant
hazardous waste firms have histories of allegations that they
failed to comply with federal and local environmental laws. The
compliance problems range from inadequate reporting to groundwater
contamination. A number of federal, state and local enforcement
actions have been initiated against these companies. In one
particular case involving the Safety-Kleen Corporation, an EPA
region has devoted resources to bringing facilities in several
states into compliance with the laws. Other companies have violated
their permits. In several cases, facilities have been forced to
cease operating for a time. Several of the facilities have
experienced accidents endangering workers and nearby residents.
These are not small or insignificant dumps, but the companies that
handle a large portion of the country's toxic wastes. They are
companies that, in most cases, have at least two facilities among
the top ten incinerators, landfills, and recyclers of TRI
chemicals. Their actions illustrate practices for disposing of some
of the most dangerous by-products of modern production. They reveal
a pattern of problems with protecting local health and the
environment.
Our examination of common destinations for off-site transfers of
TRI chemicals led to a frightening conclusion. Shipping toxic
chemicals to other off-site facilities may simply move short-term
accidents and long-term contamination from one location to another.
Such actions, by other companies, gave rise, more than a decade
ago, to the Superfund law. In 1942, the Hooker Chemical Company
began dumping chemicals into a canal. Eleven years and 42 million
pounds of chemicals later, the company covered the canal over with
dirt and sold it to the local government. A school was built on
top. It wasn't until the seventies that the chemicals began to seep
into nearby basements. After a state health survey concluded that
the contamination had endangered local residents' health, the
Federal Government offered to move people in an emergency
relocation. And the name Love Canal became a catch-phrase for the
fall-out from chemical production.
Shortly after the emergency move of the 239 families from upstate
New York, Congress passed the Comprehensive Emergency Response
Compensation and Liability Act (CERCLA) to help contain the problem
of uncontrolled hazardous waste disposal sites like Love Canal.
This federal legislation set up a system and a fund to help with
such emergencies and to help protect the health of people living
near such sites. At the time, the extent of contamination was
unknown. Most hazardous waste sites lay in uncharted territory. The
Superfund was established to provide an efficient means of cleaning
up these sites and providing immediate help for the people who were
subjected to the kinds of contamination that had imperilled the
residents of Love Canal.
THE LIST
More than a decade after the original legislation to clean up these
uncontrolled sites was passed, there are now more than 1,200 sites
listed on the National Priorities List (NPL). The sites receive, in
theory, remedial clean-up, coordinated by the EPA. The NPL was
created and is updated through a constant process of screening.
First, neighbors, owners or regulators bring a site to the
attention of the EPA. After notification, the sites may be slated
for "removal" of any contamination, and are put on the
CERCLIS list. In approximately 90 percent of these cases,
short-term removal actions clean up the immediate problem. The EPA
performs an initial assessment of the site, looking through the
site's history and testing soil and water samples. The site is
given a Hazard Ranking Score. If this score is above 28.5, as it
has been in approximately 10 percent of the cases, the site is
added to the NPL and targeted for remedial action.
The Superfund established a unique system of liability for the
sites that are listed on the NPL. Anyone who had a hand in sending
waste to the site could later become liable. This could include
generators of waste that was sent to the site, as well as the
transportation companies that sent the waste to the site. The
liability was also retroactive. Companies that had been operators,
owners, or shippers in the past could also be held liable for the
cost of clean-up. In another twist, the Superfund did not allow the
non-negligence of potentially responsible parties to play into the
judgement. Whether or not companies were aware that they were
potentially contaminating a site, they were still liable for the
clean-up costs.
An assessment of the sites on the National Priorities List
conducted in 1990 found that certain types of environmental threats
typically led to the listing of a site on the List. Groundwater
impacts were the most common cause, figuring in about 85 percent of
all sites, drinking water and soil impacts each figured in slightly
more than 70 percent of all sites. Common contaminants included
organic and inorganic chemicals.
THE SHAPE OF THINGS TO COME
While there are more than 1,200 sites listed on the National
Priorities List, the ultimate size of the list remains anyone's
guess. Conservative estimates have placed the ultimate number of
sites at anywhere from 2,000 to 10,000. In addition, it is
estimated by GAO that there are up to 400,000 sites in the country
that have received toxic or hazardous wastes. Approximately 10
percent of sites so far examined are targeted for clean-up. So, the
ultimate number of Superfund sites may be as high as 40,000. These
sites may need to be cleaned up because of the danger they pose to
health of nearby residents and the environment.
It seems logical then, that the Superfund sites of the future might
be listed among those companies that today are receiving much of
the hazardous waste generated by industrial production. While these sites do so in
a climate much more regulated than the 1940s, when the Hooker
Chemical could choose a canal in a populated area for its own
personal dump, these companies are also dealing with a world that
contains many more chemicals and in a much greater profusion and
volume than the world of the forties. A cursory glance at some of
the facilities that today receive toxic chemical shipments shows
that the amounts received in just one year can equal the contents
of Love Canal over an eleven year period.
It would be unfair to conclude that just because companies are
receiving toxic chemical shipments they are somehow endangering
health and the environment. So, we wanted to look in closer detail
at some of the facilities that are receiving these wastes to
determine if they might become the uncontrolled, dangerous
hazardous waste sites of tomorrow. Are these major recipients of
TRI chemicals Superfund sites waiting to happen? The records of
some of the largest toxic waste disposal firms are not heartening.
THE FATE OF TRI CHEMICALS TRANSFERRED OFF-SITE
Manufacturers reported releasing 3.4 billion pounds of toxic
chemicals to the air, land, and water in 1991, the most recent year
for which data are available. This information comes from the
Toxics Release Inventory (TRI), a record of the fate of toxic
chemicals used by manufacturers. Environmental regulators,
reporters and activists have long used the information as a guide
to toxics in the environment. Hundreds of reports have been written
detailing manufacturers' toxic releases.
But the Toxics Release Inventory also includes information about
toxic chemicals that manufacturers report sending to
"off-site" facilities. In 1991, manufacturers reported
approximately 3.5 billion pounds of transfers to these
destinations, a quantity even larger than the amount that these
same manufacturers reported releasing directly to the air, land and
water. Contained within manufacturers'
yearly reports are records of more than 80,000 transfers of
chemicals to what are called off-site facilities. In all,
manufacturers sent their toxic chemicals to more than 5,000 such
facilities. Every year, the Environmental Protection Agency has
produced statistical analyses showing the number of pounds of toxic
chemicals sent from or received by different states. Yet, so far,
no one has compiled a record of the actual sites that receive these
toxic chemical shipments. The difficulty of collating and
correcting the information has presented a formidable obstacle.
This report presents the first examination of the
facilities--landfills, incinerators, sulfuric acid regenerators,
energy recovery facilities--that receive shipments of toxic
chemicals. Using the 1991 TRI data, we have prepared a list of the
off-site destinations that receive the greatest volume of transfers
of TRI chemicals from manufacturers (see Table 1: Top Forty
Facilities Receiving TRI Chemical Transfers).
The facilities receiving TRI chemicals are named and ranked. By far
the largest recipient of TRI chemicals is the Rhone-Poulenc
facility in Hammond, Indiana. In fact, the third and eighth largest
recipients of TRI chemicals are also Rhone-Poulenc facilities. The
second and seventh largest recipients of TRI chemicals are General
Chemical facilities. A Timken facility in Canton, Ohio is the
fourth largest recipient of TRI chemicals. A Coulton Chemical
facility in Oregon, Ohio, is the fifth largest recipient. A
Horsehead Resource Development facility in Palmerton, Pennsylvania,
is the sixth largest recipient. Gibraltar Chemical in Winona,
Texas, and Petro-Chem Processing in Detroit, Michigan, occupy the
number nine and number ten spots on the list.
Table 2 shows the amount of TRI chemicals sent off-site for
different types of disposal. There are five major categories of
disposal: recycling, energy recovery, treatment, disposal and
unknown. The two most common methods of recycling are metals
recovery and acid regeneration, in which the waste is re-used in
production. While recycling generally has a positive appeal, some
of the problems uncovered in this examination reveal that recycling
TRI chemicals is not problem-free. For example, acid regenerators
risk accidents with sulfuric acid, an explosive substance. Energy
recovery means that the chemicals are burned and energy from the
heat produced is used for some other purpose. Treatment means the
waste is altered in some way before disposal, for example, by
burning. In the unknown category, we have grouped all the pounds of
TRI chemicals for which a final fate could not be determined.
Manufacturers most commonly report sending TRI chemicals to be
recycled. Nearly two thirds of all TRI chemicals sent off-site are
sent to be recycled. The next most common fate for TRI off-site
transfers is energy recovery. Various forms of disposal, most
notably landfilling, account for a significant portion of all toxic
chemicals sent off-site. This report also provides a more detailed
glimpse of the specific facilities that handle TRI wastes. The
report identifies the largest recipients of TRI chemicals within
specific categories, such as landfills and incinerators. The
facility receiving the most TRI chemicals to be landfilled was
operated by Pennfill in Taylor, Michigan. The largest incinerator
was operated by Rollins in Baton Rouge, Louisiana. The company
receiving the most TRI chemicals for energy recovery was Arco
Chemical in Channelview, Texas. The facility receiving the most
pounds of TRI chemicals to be injected underground was Gibraltar in
Winona, Texas. Rhone Poulenc's facility in Hammond, Indiana, was
number one on the list of facilities receiving TRI chemicals for
acid regeneration.
Acid Regenerators, who recycle TRI chemicals, receive the second
greatest volume of TRI chemicals shipped off-site, 835 million
pounds or 24 percent. The top 10 facilities received almost all of
the pounds of chemicals transferred off-site for acid regeneration.
(See Table 3: Top Ten Facilities Performing Acid Regeneration with
TRI Chemicals.) The top ten facilities dominate acid regeneration.
Together they account for nearly all of the TRI transfers sent to
this method of disposal.
The acid regeneration process takes a variety of forms. Because of
the explosive nature of sulfuric acid, this type of recycling poses
particularly acute dangers. Usually an acid regenerator takes in
waste sulfuric acid from gas refining and chemical production
industries and purifies the waste into usable sulfuric acid. The
industry leader, Rhone-Poulenc, uses a process that involves
burning the waste acid to purify it.
The third largest method used for TRI chemicals transferred
off-site was energy recovery. In 1991, 346 million pounds or 10
percent, of the TRI chemicals transferred off-site were sent to
these facilities. And the top 10 energy recovery facilities
received slightly more than a third of the chemicals disposed of in
this way. (See Table 4: Top Ten Facilities Receiving TRI Chemical
Transfers for Energy Recovery.)
In order to classify as being used for energy recovery, chemicals
had to be burned in an industrial boiler, furnace or kiln. The heat
generated had to be used for energy. If, however, a chemical does
not have a high enough heat content, manufacturers should not
report the chemical as being used for energy recovery, but instead
as having been incinerated.
Approximately two percent of the chemicals manufacturers reported
sending off-site for energy recovery did not actually have a high
enough BTU content to be used for energy recovery, and therefore
should have been classified as incinerated.
Most environmental regulators consider incineration to be a less
desirable end than energy recovery. When waste is incinerated, no
use is gained from the burning. Although manufacturers reported
sending less waste to be incinerated than for energy recovery, the
amount thus disposed of is still large, approximately 159 million
pounds, less than 5 percent of TRI transfers. The top 10
incinerators received almost half of the TRI chemicals transferred
to be incinerated. (See Table 5: "Top Ten Facilities
Incinerating TRI Chemical Transfers.")
Landfills are perhaps the most familiar destination for waste. And
indeed, landfills account for more than 5 percent of the TRI
transfers off-site, or 171 million pounds. (See Table 6: "Top
Ten Facilities Landfilling TRI Chemical Transfers.") Though the
volume of TRI chemicals received is low, these disposal sites have
presented particular environmental problems. In 1990, approximately
20 percent of all Superfund sites had been landfills. Many different
landfill companies around the country receive TRI chemicals. Unlike
acid regeneration, where the top ten facilities account for nearly
all of the chemicals disposed in this way, the top 10 landfills
accounted for less than one third of the chemicals disposed in this
way.
The operators of these relatively simple disposal sites are
required by law to protect nearby groundwater. They must ensure
that the proper liners and monitoring systems are in place. In most
cases, landfills can receive only certain kinds of
wastes. Manufacturers reported sending TRI
chemicals to approximately 1,000 apparent municipal landfills in
1991.
Less than 1 percent of all TRI chemicals transferred off-site, or
48 million pounds, was sent to underground injection wells. (See
Table 7: Top Six Underground Injection Facilities Receiving TRI
Chemicals.) The majority of the wells accepting hazardous waste
have been built in the South. Louisiana, with 70, and Texas, with
112, together accounted for 69 percent of these underground
injection wells in 1986. And the top 6 facilities, 4 of them in
Texas, received more than 95 percent of all transfers of TRI
chemicals to be injected underground.
According to EPA regulations for underground injection, the waste
must be injected at least a quarter mile below the nearest water
source. To get a permit for underground injection, companies have
to guarantee that the waste either will not come into contact with
a water source for 10,000 years, or will no longer be hazardous if
it does reach water. Several states, including Oregon, Idaho, and
Wisconsin, have banned all underground injection.
PROFILES IN DISPOSAL
THE COMPANIES THAT DOMINATE ACID REGENERATION, ENERGY
RECOVERY, INCINERATION, LANDFILLING, AND UNDERGROUND INJECTION
It would be unfair to conclude that just because companies are
receiving toxic chemical shipments they are somehow endangering
health and the environment. So, we wanted to look in closer detail
at some of the facilities that are receiving these wastes to
determine if they might become the uncontrolled, dangerous
hazardous waste sites of tomorrow. Are these major recipients of
TRI chemicals Superfund sites waiting to happen? The records of
some of the largest toxic waste disposal firms are not heartening.
In order to examine more closely the impact of these facilities on
health, safety and the environment, we have looked at specific
companies that dominate different, important sectors: acid
regeneration, energy recovery, incineration, landfilling, and
underground injection. Rhone-Poulenc operates three of the top ten
overall recipients of TRI chemicals and five of the top ten
facilities receiving TRI chemicals sent for acid regeneration. In
energy recovery, four Safety-Kleen facilities account for 13
percent of waste. Rollins Environmental Services operated the top
three incinerators receiving TRI chemicals, accounting for almost
a third of all TRI chemicals incinerated off-site. Chemical Waste
Management operates the sixth and tenth largest landfills receiving
TRI transfers, along with five other Chemical Waste Management
landfills around the country. And Gibraltar Resources underground
injection facility received almost half of all the TRI chemicals
sent to be disposed of in this manner.
ACID REGENERATION: RHONE-POULENC
In 1991, Rhone-Poulenc received more than 10 percent of the TRI
chemicals transferred off-site, and more than three-quarters of the
chemicals sent for acid regeneration. The company operates six such
facilities in the U.S., five of which were among the top ten
recipients of waste sent for acid regeneration (see Table 3: Top
Ten Facilities Performing Acid Regeneration with TRI Chemical
Transfers). Acid Regeneration is the second most common destination
for transfers of TRI chemicals. The acid regeneration process takes
a variety of forms. Usually an acid regenerator takes in waste
sulfuric acid from the gas refining and chemical production
industries and purifies the waste into high-quality sulfuric acid.
Rhone-Poulenc burns the acid to purify it.
In addition to receiving transfers of waste to be recycled,
Rhone-Poulenc facilities also reported their own releases and
transfers to the TRI. This is because, unlike CWM, Rollins and
Safety-Kleen, Rhone-Poulenc has activities classified in the
manufacturing sector, and so is required to report to the TRI (see
Appendix A "What Information Does the TRI Contain?").
In 1991, the company reported more than 34 million pounds of toxic
releases and transfers. Two facilities, one in Baytown, Texas, and
one in Institute, West Virginia, accounted for more than three
quarters of these releases and transfers. Neither of these
facilities rate as the top recipients of TRI transfers. In fact,
the Hammond, Indiana, facility, to which companies reported
shipping more than 20 million pounds of toxic chemicals for
disposal, reported only 42,000 pounds of toxic releases and
transfers of its own. The Rhone Poulenc facility in Carson,
California, was third on the list of companies receiving transfers
of TRI chemicals, receiving slightly more than 111 million pounds
of TRI transfers, but it reported only 1.5 million pounds of its
own toxic releases and transfers.
In September of 1993, the EPA found the Rhone-Poulenc facility in
Hammond, Indiana, the number one facility for acid regeneration
receipts, had violated its permit. The agency proposed a $37,350
fine for the permit violations.
Several of Rhone-Poulenc's facilities had accidents involving
sulfuric acid. In June of 1992, the Martinez and Baytown facilities
each had serious accidents involving sulfuric acid. In Baytown,
which is not among the top facilities for acid regeneration, a
loading pipe broke and sent a cloud of sulfuric acid floating
across the Houston ship channel. At least thirty people were
injured by the acid. In Martinez, the ninth largest
recipient of TRI transfers for acid regeneration, sulfuric acid
spilled and caused a fire. Two workers suffered serious burns. One
of the workers later died.
ENERGY RECOVERY: SAFETY-KLEEN
Safety-Kleen has a large share of the market for TRI chemicals sent
for energy recovery. (See Table 5: "Top Ten Facilities
Receiving TRI Chemical Transfers for Energy Recovery.") Four of
Safety-Kleen's facilities account for 13 percent of waste sent for
energy recovery. Safety Kleen is a large company with many
different parts, primarily cleaning auto parts and industrial
machines. Its large-scale facilities burn TRI chemicals through
fuel blending. Wastes are taken in from other companies and made
into fuels that power cement kilns.
Safety-Kleen's facilities are the destination of choice for many
facilities shipping TRI chemicals. In addition to operating the 3rd
and 4th largest energy recovery facilities in Holly Hill, South
Carolina, and New Castle, Kentucky, the company owns the sixth
largest incinerator of TRI chemicals, in Manati, Puerto Rico (see
Table 4: Top Ten Incinerators Receiving TRI Chemical Transfers).
In 1991, the Holly Hill, South Carolina, energy recovery facility
received 125 transfers from 29 shippers. The New Castle, Kentucky,
facility received 1,310 transfers from 552 shippers. And the Safety
Kleen incinerator in Manati, PR, received 172 transfers from 62
shippers.
Safety-Kleen's Annual Report show-cases a series of beautiful
photographs. From the cover photograph of the rolling pink and
orange desert hills at sunset, to an interior image of pale grey
boats docked in a bay, a small yellow van or truck with the black
and red Safety-Kleen emblem appears to be making its rounds. No
people inhabit these pictures; the truck leads the viewer to places
where she might want to vacation or retire.
The reality is, unfortunately, not as pretty as the pictures. In
1992, EPA Region IV targeted Safety-Kleen for enforcement actions
at more than a dozen facilities, including the New Castle,
Kentucky, facility where waste has seeped into the Bartlett Fork
Creek. This potential contamination parallels the situation found
at many of the sites that have now been prioritized for Superfund
remedial action.
In the same year, the company violated its permit at its Manati,
Puerto Rico, facility. Safety-Kleen was allowed to handle only a
certain amount of waste. But the facility was storing more than
800,000 pounds of excess toxic waste on-site. In addition, the
facility was storing more than a million more pounds of hazardous
waste in un-permitted tanks on the north and south coasts of Puerto
Rico. Some of the effluent had not been properly treated. In
response to these problems, waste was shipped off to the mainland.
And the Puerto Rican Environmental Quality Board recently fined
Safety-Kleen more than $1.4 million dollars.
INCINERATION: ROLLINS ENVIRONMENTAL SERVICES
In 1970, Rollins Environmental Services opened the first large
scale commercial hazardous waste incinerator. The company has
maintained its dominance of this sector of the business ever since
(see Table 4: Top 10 Facilities Receiving TRI Chemical Transfers
for Energy Recovery). In 1991, Rollins operated the top three
incinerators receiving TRI chemicals, accounting for almost a third
of all TRI chemicals incinerated off-site.
The company has already been involved in several federal cases
involving the Superfund. In 1988, the Bridgeport, New Jersey,
Rollins facility was found to be a Potentially Responsible Party at
nearby Superfund site, the Kin-Buc Landfill. Companies that had sent waste to Rollins were also
implicated. At least two major companies had been sending waste to
the Rollins site during the time that the incinerator had been in
turn sending its waste to the landfill that became a Superfund
site. Unfortunately for Rollins, these companies had made the
incinerator company sign an agreement protecting them from
liability.
In the 1970s, Rollins agreed to bear liability for litigation
resulting from regulatory changes that could end up costing its
customers money. Ironically, one of the companies that Rollins
tried to implicate as a Potentially Responsible Party, because the
company had sent Rollins hazardous waste, was the Hooker Chemical
Company, the same company that caused the Love Canal contamination.
The other company, the Polaroid Corporation, has so far
successfully argued that Rollins should shoulder the blame for any
contamination that might potentially involve Polaroid.
In the south, the Rollins incinerator near Baton Rouge continues to
be the site of controversy. Residents complain of odors and burning
flares. The facility is less than a half mile away from the Alsen
neighborhood, a predominately African-American neighborhood in
North Baton Rouge. One of the residents says that she can see smoke
rising from the incinerator from her porch. In 1985, the state of
Louisiana ordered the incinerator closed due to pollution problems.
The company refused to close the facility until the state began to
levy $100,000 fines for each day the facility continued operating.
Nearby residents initiated a $1 billion class action suit, claiming
that the incinerator had destroyed their quality of life and
health. Following the forced shut-down, the incinerator became the
only facility in Louisiana ever to be denied an extension of its
tax abatement. The Louisiana Department of Economic Development has
been notoriously free with such tax abatements, causing complaints
from legislators concerned with revenue and environmentalists
concerned that companies are given no incentives not to pollute in
Louisiana. But, according to the Chief of the Economic Development
Department, Rollins's environmental problems were too
extreme.
And Rollins's Deer Park, Texas, facility has also recently been the
target of environmental complaints. The incinerator was on a list
of facilities that have received radioactive waste. The list became
public when a House of Representatives committee began hearings on
Department of Defense disposal of radioactive waste. According to
information that came out in the hearing, the Deer Park incinerator
had been receiving and burning the waste for at least 11 years.
Department of Defense officials claimed the secrecy surrounding the
disposal of the radioactive waste was necessary to protect national
security.
LANDFILLING: CHEMICAL WASTE MANAGEMENT
Like other waste handlers, Chemical Waste Management, an industry
leader in landfilling, has also had problems with compliance. A
photo in the company's annual report recalls the movie 2001. In an
aisle between two rows of dark blue and black metal barrels, a
figure encased in a pale yellow plastic sheath bends over. The
ghostly figure's white plastic gloves hold a glass tube that is
inserted in one of the barrels. A vacuum cleaner hose leads from
the back of a large astronaut-like helmet and connects to a
spiraling, skinny wire tube. Reflections obscure the helmet's glass
face protector. A caption reads: "CWM's facilities carefully
sample and analyze materials in on-site laboratories to ensure that
they are properly managed." But in a number of cases involving
some of CWM's largest facilities, the EPA has alleged that this
careful analysis is exactly what CWM fails to do.
Chemical Waste Management is a subsidiary of the giant Waste
Management Incorporated (WMX). Chemical Waste Management, with
revenue of $1.5 billion in 1992, dwarfs most other hazardous waste
management companies. The company operates seven active landfills,
two deep well injection facilities and six stabilization units. The
company operates the sixth and tenth largest hazardous waste
landfills in the country. CWM's landfill in Carlyss, Louisiana
received 734 transfers of waste. The Emelle, Alabama, landfill
received a staggering 1,205 transfers from 405 different TRI
shippers (see Table 6: "Top Ten Facilities Landfilling TRI
Chemical Transfers"). Chemical Waste Management also operates
the third largest underground injection facility in the country in
Vickery, Ohio.
The Emelle, AL, landfill has been the site of a series enforcement
actions involving hazardous wastes. In 1987, the company illegally
stored and transferred Agent Orange. The waste had been given to
CWM by the state of Louisiana. The company stored 30 gallons of the
highly toxic herbicide in a warehouse in Louisiana before finally
transferring it to the landfill. Two Chemical Waste Management
employees and one state employee have pled guilty.
The Carlyss, Louisiana, Chemical Waste Management landfill has also
been involved in a number of enforcement actions brought by the
state. Beginning in 1988, the state of Louisiana has carried out a
number of inspections at the landfill. In addition to failing to
identify certain areas, the facility's operators may have allowed
hazardous wastes to contaminate the nearby ground and water.
Materials that may have been hazardous were not tested and allowed
to remain in the area where trucks are washed, potentially
contaminating the nearby roads. Wastewater leaks have been a
consistent problem turned up by Louisiana Department of
Environmental Quality inspections between 1990 and 1992. The
company recently settled with DEQ on 17 different matters of
compliance, including penalties. One issue causing the state's
crackdown was a series of eight un-reported fires in the year
between 1988 and 1989.
UNDERGROUND INJECTION: GIBRALTAR CHEMICAL RESOURCES
Less than one fiftieth of all TRI chemicals transferred off-site,
or 48 million pounds, was sent to underground injection wells.
Although low in quantity, injection facilities pose particular
risks because they rely on geology to protect nearby groundwater.
The EPA regulates companies that inject hazardous waste
underground. According to the agency, the waste must be injected at
least a quarter mile below the nearest water source. To get a
permit for underground injection, companies have to guarantee that
the waste either will not come into contact with a water source for
10,000 years, or will no longer be hazardous if it does reach
water. Several states, including Oregon, Idaho, and Wisconsin, have
banned underground injection.
The first of Gibraltar's wells began accepting hazardous waste more
than ten years ago. The company drilled a hole deep into the Texas
ground. A casing around the hole separates the injected waste from
the nearby aquifer. In 1989, Gibraltar applied for and received
clearance to build a second well for disposal of hazardous waste.
The Natural Resources Defense Council and the Hazardous Waste
Treatment Council sued the EPA, protesting that an un-built well
could not be given carte blanche. Finally, in January of 1993, the
agency decided to withdraw its earlier approval.
In 1991, Gibraltar ranked at the top of the list of underground
injection wells receiving such chemicals (see Table 7: Top six
Underground Injection Facilities Receiving TRI Chemical Transfers).
On January 7, 1993, a chemical reaction in a 15,000 gallon tank at
Gibraltar Chemical Resources in Winona, Texas, released a toxic
plume. Less than a month later,
the Environmental Protection Agency officially revoked the
company's right to inject hazardous waste into one of its two
underground injection wells. Though the EPA had initially allowed
the injection, the agency decided that an 800 foot gap in the
concrete that circled the well was just too much of a hazard to the
environment.
If anything, the following summer was more eventful. In early July,
the Texas Water Commission ordered Gibraltar to clean up
contaminated groundwater and modify the facility's
operations. The company
estimated that the changes would cost Gibraltar $1 million, a hefty
sum for a company whose previous year's revenues totalled just $43
million. Two weeks later, for three days, residents complained of
odors coming from the plant. But the Air Control Board declared the
emissions routine and not a nuisance.
By the fall, however, Gibraltar's involvement with state regulators
took a dramatic turn. The state's regulators had consolidated
environmental enforcement into one body, the Texas Natural Resource
Conservation Commission (TNRCC). Gibraltar executives failed to
report a September 9 chemical accident until the day after it
occurred. Two weeks later, reflecting on Gibraltar's history of
environmental problems, the TNRCC ordered Gibraltar to temporarily
stop receiving hazardous wastes.
Gibraltar receives waste from a variety of sources. In 1991,
companies reported 693 transfers of assorted TRI chemicals to the
company's East Texas facility. For example, Peterbilt Motors, in
Denton, TX, sent almost 8,000 pounds of Ethylene Glycol to be
injected. And Rhone-Poulenc, in Carson, CA, reported sending more
than 1 million pounds of sulfuric acid. As Gibraltar's regulatory
problems mount, these companies risk being associated with a
hopelessly contaminated site. If the facility were declared a
Superfund site all sources of waste could become potentially
responsible parties.
RECOMMENDATIONS
While many of the actions described above represent a failure of
compliance on the part of facilities that receive TRI chemicals,
certain steps could be taken to limit the dangers posed by off-site
recipients of TRI chemicals.
Recipients of TRI chemicals should have to report their own
releases and transfers of the chemicals, in order to increase
accountability. When Congress drafted the TRI law, only
manufacturing facilities had to report. In 1991, these
manufacturers reported that they sent more pounds of chemicals
off-site than they emitted directly to the environment. Yet, the
recipients of these off-site transfers do not now have to report
their own emissions to the environment. Requiring landfills,
incinerators and other hazardous waste disposal sites to report
their emissions of TRI chemicals would greatly increase the
accountability created by the Right-to-Know.
Recipients of TRI chemicals must publicize their plans to prevent
and respond to chemical accidents. The Clean Air Act Amendments
established the first framework for making corporate plans for
chemical accidents publicly available. Under the current draft of
the regulations, manufacturers must allow people to see their
assessments of the worst-case accidents. Hazardous waste landfills
and incinerators pose no less danger than manufacturers. They
should also be required to enlist the public in planning for
accidents.
Shippers of TRI chemicals should monitor the regulatory and
environmental histories of the companies to whom they ship waste.
The Superfund ensures that companies who ship waste that ends up in
an uncontrolled waste site must bear some share of the burden of
clean-up. With this expanded definition of liability, it is in TRI
shippers interest to monitor the fate of chemicals shipped
off-site.
EPA must ensure that the facilities receiving TRI wastes are
actually permitted to handle these wastes. While our report covers
the largest facilities to handle TRI chemicals, facilities most
likely permitted to receive such wastes, there are a number of
facilities that may not actually have permits to receive TRI
chemicals. Uncovering these facilities will take research, but EPA
must take the time to do this.
EPA should include examinations of off-site recipients in future
analyses of the Toxics Release Inventory. Through its annual report
on TRI chemicals, EPA each year spotlights manufacturers' releases
of toxic chemicals. But the agency has not given similar attention
to the recipients of transfers. In the future, EPA should include
lists of the names of off-site destinations in its analyses of TRI
data.
APPENDICES
APPENDIX A: WHAT INFORMATION DOES THE TRI CONTAIN?
The Toxic Release Inventory, or TRI, is a database of information
collected by the U.S. EPA. It holds information reported by
manufacturing facilities about the toxic waste that they generate
and release. They must report how many pounds of each waste
chemical they release to the air, land, and water, how much they
inject underground, and how much they transfer off-site. Although
there are limitations on who must report, the TRI is best tool
currently available to the public for tracking toxic waste from
manufacturing facilities.
A representative for a facility (from here on referred to as a
"respondent") must fill out a TRI form if all of the four
conditions below are fulfilled:
1.Only manufacturing facilities must report. Utilities, waste
treatment facilities, and mining and transportation facilities do
not have to report. Currently, federal facilities do not have to
report, though they will begin reporting in future years.
2.The facility must have 10 or more full-time employees (so small
businesses do not have to report).
3.The facility only reports data for the 350 listed TRI toxic
chemicals. Other chemicals are not reported. EPA recently has
proposed expanding this list. If the proposal is approved, the
number of chemicals in the TRI could double.
4.The facility only reports data for a chemical if it produced or
imported more than 25,000 pounds of the chemical during the year,
or used more than 10,000 pounds during the year.
U.S. EPA, some states, and some environmental groups have issued
reports summarizing TRI year-by-year. In addition, TRI has been
used extensively to look at local and global air pollution and
water pollution problems. However, few to date have extensively
examined the TRI data on shipments of waste off-site.
APPENDIX B: METHODOLOGY
The major difficulty in preparing data for this report was in
grouping individual TRI transfers together by destination. For an
explanation of this difficulty, a few definitions of TRI terms are
required. "TRI facilities" are the individual manufacturers
who fill out TRI Form R's to report releases and transfers of TRI
chemicals. "TRI submissions" are copies of the identifying
parts of these Form R's; these is one TRI submission for each
chemical that a TRI facility reports. Finally, "TRI off-site
transfers" (just called _transfers_ in this report) are data
from the Form R submissions that report the amount of the chemical
that is sent to a particular off-site destination. The amount
given for each transfer is the total pounds of a TRI chemical sent
by the TRI facility to the off-site destination during the year.
(Transfers to publicly-owned treatment works, or POTWs, are not
examined in this report and are not counted into any of our
totals). There were 80,590 non-zero transfers in the 1991 TRI
database. To find out information about individual destinations of
waste, these transfers had to be grouped together by destination.
Each set of transfer information contains the name, address, and
RCRA ID number of the off-site destination of the waste, along with
a code indicating what method of recycling, treatment, or disposal
was used on the waste. With this information, it would seem to be
a simple matter to add up all of the transfers going to a
particular destination -- just find all of the ones with the same
name and address, or the same RCRA ID. Unfortunately, the names,
addresses, and RCRA Ids in the TRI database are often incomplete or
incorrect.
To understand why this is so, remember that the TRI forms are
filled out by the shippers of the waste, not by the receivers.
Common errors or problems that occur are:
The name or address of the destination is misspelled;
The name of the destination has since been changed;
The name and address given are the mailing address of the
destination, not its physical site;
The name and address given are those of the corporate headquarters
or sales office that does business for the physical site;
The RCRA ID is written down incorrectly;
The destination has no RCRA ID;
The state or country abbreviation used was incorrect.
Most of the data quality work that has gone into this report was
intended to correct these problems. First, a computer program was
used to standardize spelling for the names and addresses of the
transfers. Blanks and punctuation were removed for comparison
purposes, and common words were changed to standard abbreviations
or removed (for instance, INCORPORATED, INC., and INC were removed
from facility names; FIRST was changed to 1ST in street names).
Some city names also had to be regularized, such as SAINT LOUIS and
ST. LOUIS. After this stage, the groups of transfers that resulted
were examined by our staff to find matches that the computer could
not detect. This often involved using the telephone to call the
destination in question to find out the correct addresses.
Destinations were also compared with EPA's FINDS database (Facility
Index System, a list of all EPA-regulated facilities in most of
EPA's major programs) to see if they existed in that database. A
reference dataset which gave the county and state of each zip code
in the U.S. was used to check the counties and states used in the
transfer addresses. Finally, staff looked at all of the individual
transfers going to the largest poundage destinations to try to make
sure that none had been mis-assigned. By using these methods, the
80,590 transfers were grouped into about 5,300 destinations.
Although we can not guarantee that no transfer has been
mis-assigned to a destination, we are confident that the possible
error introduced is low enough so that it should not greatly affect
the totals given for the destinations listed in this report.
Totals are given in this report are generally rounded off to the
nearest million pounds. In general, reporting all digits in a TRI
total should not be done since EPA only requires no more than 2
significant digits for reporting releases (Toxic Chemical Releases
Inventory Reporting Form R and Instructions, pg. 27). For this
report, transfers that were reported as "release ranges" were
counted as a number of pounds equal to the center of the range
(i.e. 1-10 pounds = 5 lbs, 11-499 lbs = 250 lbs, 500-1000 lbs = 750
lbs).
The TRI off-site shipments offer a wealth of information about
incinerators, hazardous waste landfills, and waste recyclers. For
instance, assume that you are interested in a particular
incinerator. The incinerator does not have to report to TRI, since
it is not a manufacturing facility. But if any TRI facility sends
waste there, they must report the name and address of the
incinerator along with the amount of waste that was sent. It is
possible to search TRI for all shipments going to the incinerator
and add them up. This gives you a list of chemicals that the
incinerator is known to burn, a minimum amount of each chemical
that is burnt, and a partial customer list for the incinerator. We
have done this for all facilities in the 1991 reporting year of TRI
(the latest year of data available at the time this report was
written). The facilities that waste was sent to range from
well-known hazardous waste recycling, treatment, disposal
facilities to small municipal solid waste dumps and farms.
Figuring out which TRI off-site transfers were going to which sites
was difficult. TRI respondents often misspell the names and address
of off-site facilities, or give incomplete information. U.S. EPA
does not check the off-site names and addresses for misspellings or
missing information. Therefore, we had to use a complicated
computer procedure and our own judgement to try to figure out where
the waste was going in many cases. The first question to consider
is the size of the total waste stream in the TRI "universe"
of facilities. How much total waste is being shipped each year?
Surprisingly enough, even this basic question can be answered
differently depending on how you phrase the question. To start to
see why, look at the table below (all numbers are given to two
significant digits, since that is the level of accuracy required by
TRI):
Year Total Lbs Shipped* Total Lbs Shipped & Released
1987 2.0 billion 21.0 billion
1988 1.9 billion 8.2 billion
1989 1.0 billion 5.9 billion
1990 0.9 billion 5.0 billion
1991 3.5 billion 7.2 billion
* does not include pounds shipped to POTWs]
The table shows the total off-site shipments, or transfers, for
each year. It also shows the total amount of TRI chemicals released
and transferred by year. The first thing you might notice is that
the totals decrease rapidly after the first year, then increase
again in the last year. Both the decrease after 1987 and the
increase in 1991 are, to a large extent, artifacts of the way the
data was reported rather than indications of a true increase or
decrease in waste. The decrease after 1987 was mainly due to
changes in which chemicals were on the TRI reporting list. The TRI
chemical list is supposed to contain chemicals which meet certain
criteria for toxicity. Every year, some chemicals may be added to
or subtracted from the list by EPA either on its own authority or
in response to petitions from the public. After 1987, EPA granted
petitions to "de-list" a few of the largest poundage
chemicals in TRI. Since these chemicals did not have to be reported
in future years, the totals in future years declined precipitously,
although no actual change in waste production may have occurred.
Another reporting change caused the large increase in the 1991
totals. In that year, EPA implemented the Pollution Prevention Act
of 1990 (PPA), a law which forced TRI respondents to start
reporting off-site shipments to recycling and waste-to-energy
facilities. Before the PPA, TRI respondents only had to report
off-site shipments to treatment or disposal facilities. In U.S.
EPA's official yearly TRI data release, year-to-year comparisons
are made by removing from the database all records of chemicals
that were added or subtracted from the chemical list. Also, EPA
compares transfers from multiple years by attempting to screen out
transfers to recycling or waste-to-energy facilities. This allows
year-to-year comparisons to be made while removing most changes
that are due to changes in reporting requirements. In our report,
we have left all records in the database, since we are considering
only the 1991 data year. Therefore totals from this report may not
match the numbers given out in other sources.